Revenue Procedure 2026-17 creates a limited window to revoke certain “irrevocable” §163(j) elections, including the RPTOB and CFC group elections, in light of OBBBA-driven changes.

The Bill represents a significant shift toward streamlining corporate restructuring and reducing the regulatory friction for M&A transactions. Here is a summary of the key provisions from an M&A and restructuring perspective.

On March 10, 2026, the Spanish Council of Ministers approved the signing of a new double tax treaty between Spain and the Netherlands, formally replacing the current agreement signed in 1971, one of the oldest treaties in Spain’s tax treaty network.

Financial institutions do not have a core banking problem. They have a decisioning problem. For decades, banks optimized Systems of Record (SoR) to post transactions with precision and maintain regulatory integrity. That battle has largely been won. What now differentiates institutions is not how accurately they book activity, but how intelligently and quickly they make decisions.

On March 12, 2026, the Commodity Futures Trading Commission (CFTC) issued two key documents aimed at clarifying regulatory oversight in the prediction markets – an Advanced Notice of Proposed Rulemaking (ANPRM) and a staff advisory letter to Designated Contract Markets (DCMs). In this article, we will highlight key takeaways from both.

The CBUAE’s five-pillar Resilience Package (17 March 2026) is a proactive intervention backed by the CBUAE’s AED 1 trillion asset base.

In this article, Tania Henriques, Jonathan Zatz, and Connor Gibbs share perspectives on FinCEN’s Investment Adviser AML Rule, including the data, governance, and control considerations that can help firms move from reactive compliance to a more sustainable approach.

Explore key transitional issues for FY2025 CIT finalization in Vietnam under Decree 320/2025/ND‑CP and Circular 20/2026/TT‑BTC.

Bigbank, a pan-European bank headquartered in Estonia, sought to execute its inaugural SRT transaction as part of its broader capital management strategy. A&M advised the bank on the transaction, helping it successfully enter the securitisation market and structure a capital relief solution aligned with its growth ambitions.

A&M’s Digital & Technology Services team explores how organizations can evaluate frameworks, platforms, domain-specific solutions, and hybrid models for agentic AI, and what those choices mean for governance, scalability, and long-term value.

The UAE has now issued Ministerial Decision No. (24) of 2026 (the “Ministerial Decision”), setting out the detailed implementing rules for the R&D Tax Credit framework introduced under Cabinet Decision No. (215) of 2025 for the purposes of the UAE Corporate Tax regime.
This is a significant milestone.

After years of rising growth multiples, Europe’s software market is repricing. Our first Navigating Dealflow: European Software Quarterly brings a clear view of how this reset is changing M&A, where valuations are landing, and which segments are holding up.

On February 13, 2026, the German Federal Ministry of Finance (Bundesfinanzministerium or BMF) released a draft of new administrative principles on the definition and creation of permanent establishments (PEs) under domestic tax law (§ 12 AO, § 13 AO) and double tax treaties (Art. 5 OECD Model). The draft represents the most significant update to Germany’s PE framework since the last amendment in 2026 and incorporates extensive BFH case law as well as the OECD’s 2025 Model Convention and Commentary.

Tokenization Tax Planning for RWAs: Classification, PTP risks, FIRPTA, portfolio interest, VAT, and withholding. Design tax from day one.